Washington Highlights

December 20, 2013—The Office of Management and Budget (OMB) Dec. 19 released its final guidance on “Uniformed Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The guidance, termed the Omni-Circular, supersedes the requirements of various other OMB cost circulars, including OMB Circular A-21, “Cost Principles for Educational Institutions.”

The guidance continues the cap on the reimbursement of administrative costs to 26 percent of modified total direct costs. OMB commented that “[f]uture reform efforts may eventually seek to incorporate the Cost Principles for Hospitals” in the Omni-Circular, but for now, “Principles for Determining Cost Applicable to Research and Development Under Grants and Contracts with Hospitals” remain in effect.

The final guidance is scheduled to appear in the Dec. 26 Federal Register. The effective date of the new guidance document is Dec. 26, 2014. However, the audit requirements appear to “be effective for non-Federal entity fiscal years beginning on or after the effective date of this guidance.”